Supplier Code of Conduct (SCoC) and training

The requirement to comply with the Supplier Code of Conduct is detailed online, through various Master agreements, and in our PO Terms and Conditions. Additionally, suppliers acknowledge the Supplier Code of Conduct during the Microsoft supplier setup process.

Refer to the Supplier Travel Guidelines PDF.

Suppliers and their employees, personnel, agents, and subcontractors (collectively referred to as "Suppliers") must adhere to this Supplier Code of Conduct while conducting business with or on behalf of Microsoft. Suppliers must require their subcontractors to acknowledge and implement the SCoC in their operations and across their supply chains. Suppliers must promptly inform their Microsoft contact, a member of Microsoft management, or the contacts provided at the end of this document when any situation develops that causes the supplier to operate in violation of this Code of Conduct.

All Microsoft suppliers must conduct their practices in full compliance with all applicable laws and regulations and in compliance with Microsoft requirements, whichever are stricter.

Additionally, beginning in Microsoft’s 2024 fiscal year, there is a requirement for a supplier’s authorized representative to annually (1) attest to the SCoC in SupplierWeb and (2) complete the SCoC training course. This will be implemented in a phased approach over the course of the 2024 fiscal year. Suppliers will receive email communication from Microsoft when their annual attestation is due.

All contacts can be updated in SupplierWeb. Access the contacts page in the supplier profile to make updates directly to your SCoC compliance contact. This person(s) will receive information regarding the SCoC from Microsoft.

Companies may be doing business with Microsoft in a variety of capacities. To the extent that a company is exclusively engaged with Microsoft in a Partner capacity and is not providing any procured goods or services to Microsoft, compliance with Microsoft's Partner Code of Conduct and related training requirements would be sufficient at this time. However, if a company is engaged with Microsoft in both a partner and supplier capacity, it is expected that in addition to compliance with the Partner Code, they must comply with the Microsoft Supplier Code of Conduct (SCoC).

Suppliers can find information online via the Supplier Accessibility Procurement page.

Please visit Hierarchy of Controls | NIOSH | CDC.

Microsoft trusts our suppliers to ensure that all of their employees working with or on behalf of Microsoft, both with and without network/building access, are trained annually on our Supplier Code of Conduct.

Suppliers can choose from the following methods to meet their SCoC training obligations:

• Suppliers can leverage Microsoft’s SCoC training course (Note: this link does not record course completion status)

• Suppliers can download a SCORM package of Microsoft’s SCoC training course for use in their own LMS (Learning Management System)

• Suppliers can develop their own training method and materials to train their applicable workers on Microsoft’s SCoC content

Any external staff* engaged in services for Microsoft, or who will bill time to Microsoft, or who otherwise work on Microsoft matters are required to complete SCoC training and agree to comply with the SCoC. External staff includes contractors, vendors, business guests, and Outsourced staff.

*Individuals who 1) are engaged in providing services for Microsoft, 2) bill time to Microsoft, or 3) otherwise work on Microsoft matters, are required to complete the Supplier Code of Conduct training.

This requirement is not time specific and applies to anyone working with or on behalf of Microsoft for any period. We trust our suppliers to use appropriate judgement in how to interpret this.

Suppliers can choose from the following methods to meet their SCoC training obligations:

• Suppliers can leverage Microsoft’s SCoC training course (Note: this link does not record course completion status)

• Suppliers can download a SCORM package of Microsoft’s SCoC training course for use in their own Learning Management System (LMS)

• Suppliers can develop their own training method and materials to train their applicable workers on Microsoft’s SCoC content

Microsoft pre-access training is in addition to the annual supplier training obligation. It is the responsibility of the supplier to meet the annual training requirement for each external staff engaged in services for Microsoft, regardless if the Microsoft pre-access training was also completed that year.

Yes, in addition to supplier’s training obligations, Microsoft requires and automatically provides SCoC training to all external staff requiring access credentials to the Microsoft corporate network and/or buildings before they obtain their access rights. This is referred to as pre-access/onboarding training and managed by Microsoft.

They are still required to complete SCoC training on an annual basis. Their employer (Microsoft supplier) has the responsibility to ensure they are trained annually.

The SCoC training takes approximately 35-45 minutes to complete.

Yes, the Microsoft’s SCoC training course is localized in 26 languages: Albanian, Armenian, Chinese (simplified), Chinese (Traditional), Croatian, Czech, English, French, German, Greek, Hungarian, Italian, Japanese, Korean, Macedonian, Polish, Portuguese (Brazilian), Portuguese (Portugal), Romanian, Russian, Serbian, Slovenian, Spanish, Turkish, Ukrainian, Vietnamese. Transcripts of the SCoC training course in all 26 languages may also be downloaded at the aforementioned link.

Access your supplier account on SupplierWeb and select the 'I need help' button located in the lower right corner.

All external staff who are onboarding through Microsoft systems, requiring access, must complete training prior to being granted access to Microsoft’s Corporate Network and/or buildings. As part of the external staff setup process, external staff workers receive an email notification containing a link to complete the online training. Once the external staff worker completes the training, the process for granting access to Microsoft’s Corporate Network and/or buildings will proceed.

Note: In addition to the pre-access/onboarding training requirement managed by Microsoft, suppliers are accountable to train all employees and agents working on Microsoft matters on an annual basis.

The Americas screening accounts do not support screening in the Asia or EMEA regions. To learn more about background screenings in Asia or EMEA, review this FAQs PDF. 

You may also contact esscrng@microsoft.com for inquiries related to background screenings for external staff working in the Asia or EMEA regions.

Contact supscrn@microsoft.com for set-up assistance for a background screening (for suppliers located in the United States, Canada, or Latin America)

Suppliers will receive training materials from the background screening supplier on how to initiate a background screen.

Upon account set up, suppliers shall designate a representative to upload their employees' contact information to the background screening supplier's online platform. The system will initiate an email request to employees' inbox.

Employees will then input their personal information required for a background screening. Thereafter, the background screening supplier conducts the research and reports results via its online platform.

If discrepant or derogatory information is discovered, it will be viewable by the suppliers' designated representative and Microsoft Global Security only.

Employees can request a copy of their background screening report and the supplier shall be responsible to provide it.

To the extent permitted by law, background checks will typically include review of the following components: identity check, criminal record review, sex offender registry check, and global sanctions list review. For certain placements, Microsoft may require additional screens (for example, education verification, prior employment verification, verification of job-related licenses, consumer credit report review, drug testing, and/or other relevant information-gathering).

Background checks typically take the following average times to conduct; however, there are exceptional circumstances that can take longer or shorter turnaround times to produce.

• 3–5 business days in the United States
• Up to 7 business days in Canada
• Up to 18 business days in Mexico
• 5-10 business days in other LATAM countries

Suppliers should communicate tentative start dates accordingly.

Yes. First, suppliers should initiate a background check as soon as their employee has been identified for placement at Microsoft. Next, suppliers should remind their employees of the need to complete the information in the online tool, ideally within 48 hours. Employee should make sure the information submitted into the screening form is as accurate and complete as possible. Suppliers should also urge their employees to assist the background screening supplier by answering any inquiries promptly. Last, if employees have not received the request via email as expected, they should check their "junk" or "clutter" folders to ensure it has not been rerouted.

Microsoft can assist with performing a self-pay screen. This will allow for a supplier employee to be screened when the supplier does not have an account set up. The screen will be paid for upon submittal by the person being screened. Suppliers' employee will receive a notification once the screening is complete. If required, the background screening identification number can be provided to the supplier.

Contact supscrn@microsoft.com if you have an onboarding request.

Microsoft requires that suppliers conduct pre-placement background checks on all their personnel who will require any physical or virtual access to Microsoft. This includes owned or leased facilities or Microsoft corporate network resources. This requirement applies to all locations where background screening has been implemented.

Yes, a background check is required for any former employee or former supplier to Microsoft.

Yes. Anyone who will be performing work with Microsoft in a location where Microsoft has implemented a background screening program is required to be screened if they need physical or virtual access to Microsoft.

Microsoft requires that suppliers conduct pre-placement background checks on all their personnel who will require any physical or virtual access to Microsoft. Any supplier employee who refuses a background screen is not eligible to obtain Microsoft credentials for physical or corporate network access.

When considering information in an individual's background, suppliers should abide by the laws within the jurisdiction their employee is being considered for placement. If in doubt, consult with your employment law advisors. When considered for placement at Microsoft, individuals should demonstrate a history of conduct that is trustworthy and reliable and does not pose a threat of risk to people, property, or proprietary information. The supplier must determine whether the background screening report contains information such as criminal convictions or other matters that render the individual unsuited to perform work connected to Microsoft. Examples of convictions that may be reasonably related and should be reviewed by the supplier include but are not limited to: crimes of dishonesty (that is, theft, embezzlement, fraud, forgery, etc.) and crimes of violence (that is, murder, rape, kidnapping, assault, robbery, stalking, harassment, etc.).

Supplier must certify that it has conducted pre-placement checks consistent with the Supplier Preplacement Policy and that any convictions, serious delinquency or debt, or any other matters disclosed in the background check that may render the individual unsuitable for placement at Microsoft has been reviewed by the supplier, and that the supplier has determined that the individual is suited for access to Microsoft owned or leased facilities or access to Microsoft virtual resources such as email and corporate network access.

Microsoft reserves the right to review and discuss with suppliers, in a manner consistent with applicable law, pre-placement background information for any individual submitted for placement suitability by suppliers who may require physical access to Microsoft owned or leased facilities or virtual access to Microsoft resources such as email and corporate network access. Based on that review, Microsoft may prohibit access as it deems appropriate to any individual submitted for placement by suppliers. The supplier background screening representative will be notified of Microsoft's suitability decision.

A background screen can be reused for placement for up to 18 months if the person does not have a break in service from being on a Microsoft assignment for more than 30 consecutive days and has not changed employers.

A screen is valid for 18 months if the person does not have a break in service from being on a Microsoft assignment for more than 30 consecutive days and does not change employers.

The background screen cost can vary depending on fees incurred by the background screening provider while conducting the screen. Different jurisdictions and courts may charge fees; however, on average, the cost of a background screen is approximately $40 in the United States. 

Contact supscrn@microsoft.com for background screen pricing in Canada and LATAM.

Costs of doing business with Microsoft, such as background screening fees, are the responsibility of the supplier company, unless there is a negotiated contract that specifies otherwise.

Yes, for certain positions involving customer engagements or contractual requirements, a rescreening may be required. The assigned Microsoft representative will notify the supplier when a rescreening is required.

Please contact Microsoft’s Supplier Screening Program with any questions related to the background screening process. Email supscrn@microsoft.com.   

If suppliers' employees have questions, they should contact their Human Resources department or management directly.

We require companies that do business with Microsoft in the United States:

• To provide their employees physically located in the U.S. with at least 15 days of paid leave each year. This requirement applies to suppliers with 50 or more employees in the United States and to their employees who have worked for them for at least 1500 hours in the prior 12 months and who require access to Microsoft’s network and/or facilities.
• To staff Microsoft projects only with W2 employees of their companies, and not independent contractors, when access to Microsoft’s network and/or facilities is required.
• To provide employee health benefits that comply with the Patient Protection and Affordable Care Act of 2010 (the “ACA”) to their employees physically located in the U.S., who work for them 30 or more hours per week and who are staffed on Microsoft projects when access to Microsoft’s network and/or facilities is required.
• To provide their employees physically located in the U.S. with at least 12 weeks of paid parental leave at 66% of pay with a cap of $1,000 per week or commensurate with Washington state’s paid family leave law. This paid parental leave requirement applies to suppliers with more than 50 employees in the United States and to their employees who have worked for them for at least 1500 hours in the prior 12 months and who require access to Microsoft’s network and/or facilities.

This builds on steps Microsoft has taken to increase workforce inclusion and support employees and their families. We believe that it was the right step for our business.

Paid time off and paid parental leave benefits both employers and employees by contributing to a happier and more productive workforce. We have long recognized that the health, well-being, and diversity of our employees helps Microsoft succeed. That's why we have long provided industry-leading benefits for our employees, including paid time off and paid parental leave. The people who work for our suppliers are critical to our success, and we want them to have these benefits.

Review the paid time off Microsoft blog post.

Review the paid parental leave Microsoft blog post.

Yes.

If any supplier, regardless of location, has employees physically located in the United States and who are performing work on a Microsoft project that requires access to Microsoft facilities or network, then these requirements apply for such employees.

We hope you will provide benefits to all your employees, but our requirement is specific to those people who do substantial work for Microsoft, which we define as those requiring access to our facilities and/or the corporate network.

Suppliers must comply with Washington's paid leave law. Suppliers may take advantage of Washington's program to provide the paid leave as applicable. Suppliers may, of course, offer more generous benefits to their employees.

Suppliers must provide their employees with at least 12 weeks of paid parental leave at 66 percent of pay with a cap of $1,000 per week or commensurate with Washington's paid family leave law. Suppliers may take advantage of state programs to provide the paid leave if those programs apply but will need to supplement any state-provided leave to reach our standard. Suppliers may, of course, offer more generous benefits to their employees.

We do require suppliers to pass down these obligations to their subcontractors.

The paid time off, W2, and healthcare requirements went into effect in 2015; the paid parental leave requirement went into effect January 1, 2020.

No. The 1,500 hours is not tied to Microsoft work. It is based on the time they have worked for their employer. That time may or may not have started with a Microsoft engagement.

Suppliers can rely on state administered paid parental leave benefits, but to the extent the state-administered leave does not meet our required minimum, the supplier is responsible for administering their paid parental leave program to reach our standard and creating a compliant environment that benefits their employees.

No. The 15 days of paid time off each year for the eligible employees will be either 10 days of paid vacation and five days of paid sick leave or 15 days of unrestricted paid time off.

Microsoft may engage an individual or a small service provider through Microsoft Procurement's Small Service Provider (SSP) Program under necessary and applicable requirements.

The purpose of the Minamata Convention is to protect human health and the environment from anthropogenic emissions and releases of mercury and mercury compounds.

The Stockholm Agreement on Persistent Organic Pollutants (POPs Agreement) is a global treaty to protect human health and the environment from chemicals that remain intact in the environment for long periods, become widely distributed geographically, accumulate in the fatty tissue of humans and wildlife, and have harmful impacts on human health or on the environment.

The Basel Convention is an international treaty designed to reduce the movements of hazardous waste between nations, and specifically to prevent transfer of hazardous waste from developed to less developed countries (LDCs).

To help achieve the company’s broader sustainability goals, Microsoft has implemented additional sustainability requirements for suppliers. The following language was added to our Supplier Code of Conduct in 2020 to require our suppliers to disclose and reduce their greenhouse gas emissions:

Suppliers must disclose complete, consistent, and accurate scope 1, 2 and 3 greenhouse gas (GHG) emissions data and/or components required to calculate GHG emissions data, via CDP or an alternative method identified by Microsoft. Suppliers may also be required to provide independent or third-party assurance over such disclosed emissions data. Suppliers must also provide and achieve plans to reduce absolute GHG emissions by a minimum of 55% by 2030 or an alternative reduction target pursuant to the baseline established in their supplier contract or in other written communication with Microsoft. Specific requirements for data disclosure, assurance, reduction targets, and achievement of planned reductions, including the timing of Supplier conformance, will be set forth in their supplier contract or in other written communication with Microsoft.

By sharing clear reduction requirements and harmonizing the asks we and other large buyers are making of our suppliers, we aim to send a strong collective market signal. We have harmonized our requirements to align with those of leading industry groups such as the Exponential Roadmap Initiative, in order to avoid compliance burden to suppliers.

Reducing GHG emissions to limit climate change in line with a 1.5-degree Celsius pathway is a global imperative for everyone. The best available science indicates that every organization needs to do even more in far less time than previously thought. As outlined in our January 2020 sustainability announcement, Microsoft is committed to becoming carbon negative (removing more carbon out of the atmosphere than the company emits) by 2030. To achieve this goal, we must continue to engage with our suppliers and build on existing efforts to track and reduce our Scope 3 emissions, which contribute a majority of Microsoft’s overall emissions. Our policies are designed to achieve these goals in partnership with our suppliers.

In the Greenhouse Gas Protocol, GHG emissions are organized into three categories, or “scopes”:

• Scope 1 covers all direct GHG emissions caused by sources owned or controlled directly by your company, (for example, emissions from combustion in owned or controlled boilers, furnaces, vehicles, etc. or emissions from chemical production in owned or controlled process equipment.)

• Scope 2 covers indirect GHG emissions caused by the generation of energy purchased by your company, such as electricity, steam, and heating/cooling.

• Scope 3 covers all other indirect emissions not included in Scope 2 that occur in the value chain of your company both upstream and downstream, (for example, emissions generated by your suppliers during production or your customers during their use of your products.)

In most cases, Scope 3 emissions represent the vast majority of a company’s total GHG emissions, which is why it is critical to include in corporate emissions reduction targets.

Microsoft follows the Greenhouse Gas Protocol. While we do not require specific methodologies be followed, we do require our suppliers to report complete, consistent, and accurate data.

Yes. During our feedback sessions, we heard from suppliers that a lot of existing resources are quite technical. As such, we have developed some introductory sustainability learning resources designed to help our suppliers measure and report their GHG emissions, develop clean energy strategies and reduce their energy-related emissions. These are available publicly on Tools and resources - Microsoft sustainability: 

• GHG Emissions Accounting 
• Energy efficiency 
• Renewable energy procurement 

 Additional GHG accounting resources: 

• View the GHG Protocol 
• Use the EPA GHG Emissions Calculator 
• Learn more about Microsoft Cloud-based Carbon Emissions

Additional GHG reduction resources: 

• Visit the SME Climate Hub 
• Learn about the Clean Energy Buyers’ Association (Microsoft suppliers are eligible for certain member benefits. Please contact supplychain@cebuyers.org to inquire.)

Learn about The Climate Group’s RE100, EP100, EV100 and SteelZero programs

Yes. Microsoft is partnering with the International Finance Corporation (IFC), a sister organization to the World Bank, which will work with qualifying Microsoft suppliers in emerging markets, to identify technical solutions reducing GHG emissions, provide implementation assistance and offer financing solutions to help them make investments in more efficient and low-carbon operations.  

Learn more about our partnership with IFC 

Additionally, our Climate Innovation Fund has committed to investing $1 billion over four years into new carbon emissions reduction technologies. 

We’ll focus our funding on investments primarily based on four criteria: (1) strategies that have the prospect of driving meaningful decarbonization, climate resilience, or other sustainability impact; (2) additional market impact in accelerating current and potential solutions; (3) relevance to Microsoft by creating technologies we can use to address our unpaid climate debt and future emissions; and (4) consideration of climate equity, including for developing economies. 

Learn more about the Climate Innovation Fund

We heard from suppliers that measuring, reporting, and reducing greenhouse gas emissions require a great deal of time and expertise, especially for organizations new to the process.  We therefore intend to take a phased approach in rolling out these disclosure and reduction requirements to our suppliers. 

As such, your company’s specific requirements for emissions data disclosure, assurance, reduction targets, and achievement of planned reductions, including the timing of conformance, will be set forth in your supplier contract or in other written communication with Microsoft.* 

*If, prior to July 2020, you were contractually required by Microsoft to submit your carbon emissions, then you will need to continue to meet any deadlines relevant to your contract.

SCoC obligations are carried down to supplier's subcontractors for work that is directly related to a Microsoft contract.

Microsoft defines a supplier’s “subcontractor” as a third party to whom a supplier delegates its obligations under an Agreement, or a Supplier Affiliate not contracting directly with Microsoft. This means that the supplier has hired another company or person to complete a portion of or all the goods/services being delivered to Microsoft.

All supplier categories are in scope to obtain written permission to use subcontractors on any Microsoft engagement. The supplier must request from the Microsoft business owner’s approval to use a subcontractor for each engagement. There are no blanket approvals for suppliers to use subcontractors beyond the specific, approved engagement.

Approval can be provided or removed at any time during the engagement via a SOW Amendment and/or Change Order. Written approval to use subcontractors on an engagement expires on the SOW termination date unless a new SOW and/or written permission is provided.

Yes, the supplier’s subcontractor must complete SCoC training.